TRPR (TPD) Update CAS numbers and Compliant RTV

The past week has seen a dramatic change for those going through, or intending to go through, the TRPR 2016 (TPD) Notification process. The MHRA no longer require CAS numbers or ingredient details if an individual ingredient represents less than 0.1% of the final formulation. The relevant portion of the MHRA email update is below.

Commission Implementing Decision (EU) 2015/2183 states that ingredients present at a level below 0.1% of the final product formulation may be deemed confidential or a trade secret. Below that level, we will allow ingredients to be considered as confidential in the notification. As such, ingredients present at a level below 0.1% of the final formulation can now be described collectively in the notification by an umbrella term such as ‘strawberry flavouring’. In these cases, the notifier must gain the following from the ingredient supplier: (i) adequate assurance of quality and safety to allow the notifier to accept full responsibility for the product under s31(3)(g) of the TRPR and (ii) an assurance that the ingredient supplier would disclose the composition to the competent authority (MHRA) in confidence the event of a safety problem with the product. Notifiers must satisfy themselves as to the safety and quality of their product but may wish to seek assurances that: a) the ingredient complies with applicable EU food flavouring legislation (Regulation EC 1334/2008). b) the flavouring substances contained within the flavour are listed in the EU list of flavouring substances as defined by Regulation EU 872/2012. c) The ingredient formulation does not include any substance banned under Article 7 of the Tobacco Products Directive.

FlavourArt Italy has issued a statement that addresses points (i), (ii), a), b), c). The statement satisfies MHRA requirements and enables Notifiers to submit without the need for CAS numbers.

For anyone wishing to continue selling Ready To Vape flavoured eliquid, or anyone looking to stock Ready To Vape flavoured eliquid, we will soon have the full range of TRPR (TPD) compliant liquids in stock. There are 51 flavours in 4 strengths and we will also have unflavoured base Nicotine liquid in 3 strengths for 50/50 PG/AVG and an all AVG option, 4.5mg/ml, 9mg/ml, 18mg/ml. We are currently selling through our current stock ready for the new compliant range arriving. If you are looking to order or want more information, please contact us. If we know your requirements in advance, we can make sure we order extra stock.

Here is the list of RTV liquids that will be available. All have EC-ID numbers which will be released shortly.